NUTRITIONAL LABELLING GUIDANCE PACK

NUTRITIONAL LABELLING GUIDANCE PACK

SECTIONS 1. What is the legislation regarding nutritional labelling? 2. Who will enforce this legislation? 3. Where do we start? 4. What is Pre- Packed Food? 5. What is Non-Pre- Packed Food? 6. What are Pre- packed foods for Direct Sale? 7. What are the benefits of providing this information voluntarily? 8. What information will you have to provide? 9. How can we ensure that the information is accurate? 10. Describing Dishes, Food Names and Menu Descriptions 11. Can we make specific health claims? 12. How else can we encourage healthy eating in our operation? 13. Key Action Point Summary

1. WHAT IS THE LEGISLATION REGARDING NUTRITIONAL LABELLING? This guide is designed to inform and help you make the right decisions with regards to the requirements of the Nutritional Labelling aspect of the new Food Information Regulations 2014 (FIR) and to give guidance on describing foods. The guide includes; details of legislative requirements, key action points and practical advice for you to consider. You can use these guidance notes along with the pack power point to provide a presentation for your colleagues. The Food Information Regulations 2014 (FIR) are the UK s domestic regulations that establish the enforcement measures for Regulation (EU) No 1169/2011 on the provision of food information to consumers (EU FIC) Since 13th December 2014, all caterers (known as Mass Caterers in the regulation guidance) have the mandatory responsibility under these regulations, of providing information on the 14 major allergens to their customers. This is covered in our Allergen Awareness and Labelling Guide. Nutrition labelling for most pre- packed (see section 4) food will become mandatory from 13th December 2016. This labelling is known as a nutrition declaration (sometimes referred to as back of pack nutritional labelling). There is no requirement in EU FIC for nutrition information to be provided for food that is sold non- pre- packed (see section 5) or pre- packed for direct sale (see section 6). However, if you decide to give this information voluntarily to your customers, you must follow the rules with regards to the content of the information and how you present it to your customers. If you have made a specific health claim about a certain foodstuff, under the regulations you must provide the full nutritional declaration. You should also be aware of Regulation (EC) 1924/2006 on nutrition and health claims made on foods. You will also find specific guidance about making health claims in Section 11 of this guide.

2. WHO WILL ENFORCE THIS LEGISLATION? Responsibility for nutrition labelling policy has been transferred to the Department of Health from the Food Standards agency. They work with local authority enforcement officers in trading standards and environmental health departments. 3. WHERE DO WE START? The nutrition labelling section of this legislation means that we must first understand what category of foods we are serving. KEY ACTION POINT 1: Analyse your products and decide if you have to provide nutritional declarations for any of them in order to comply with the Food Information Regulations. The following section will help you:

4. WHAT IS PRE- PACKED FOOD? The term Pre- Packed Food refers to any food put into packaging before being offered for sale, for example a packet of biscuits, a sealed packed of crisps, a jar of sauce, a cereal bar or a can of soup. ALL THE FOLLOWING MUST APPLY: The food is either fully or partly enclosed by the packaging The food cannot be altered without opening or changing the packaging The product is ready for sale to the final customer in a retail outlet or to a mass caterer It is likely that you will be providing pre- packed foods to your customers, perhaps at conferences or buffets or selling them in your retail outlets and you will already be able to see some of the nutritional declarations, placed by their manufacturer, onto their packaging. It will look like this:

5. WHAT IS NON-PRE-PACKED FOOD? In a retail environment, this is likely to apply to foods which are sold loose from a delicatessen counter (e.g. cooked meats, cheeses, cooked sausage rolls, cooked samosas, pies and dips), fresh pizza, salad bars, bread sold in bakery shops, meat from butchers, pick and mix confectionery (including individually wrapped sweets and chocolates), etc. In a catering environment, this is likely to apply to foods that are not sold pre- packed but loose, for example meals served from a counter, served on a buffet or served in a restaurant, also foods that are packed on the sales premises at the consumer s request. For example: food from a takeaway outlet.

6. WHAT ARE PRE- PACKED FOODS FOR DIRECT SALE? These are foods that have been packed on the same premises from which they are being sold. Foods pre- packed for direct sale are treated in the same way as non- pre- packed foods in EU FIC s labelling provisions and do not have the mandatory nutrition declaration requirement. For a product to be considered pre- packed for direct sale it is expected that the customer is able to speak with the person who made or packed the product to ask about ingredients. Foods that could fall under this category could include; prepared salads, meat pies made on site and sandwiches made and packaged, perhaps in a central production unit and sold from the premises in which they are made. You may already be thinking about some of your food items that do not fall neatly into this category, such as sandwiches that are made in your central production unit and then transported to other sites and locations, where perhaps it would not be as easy for the customer to speak to the person who made the sandwich. On these foods, the following should be clear on the label: The name of the food *you will find recommendations for describing your products later in Section 10. Allergen information *Please refer to the TUCO Allergen Guide

Here is some guidance that has been put together by the British Sandwich Association following consultation with local authorities and the Food Standards Agency: Reduced labelling may be used where sandwiches are: 1. Produced, packed and sold within the same retail premises; or 2. Produced and sold non- prepacked within the same premises; or 3. Produced at a central location and sold (prepacked for direct sale or nonprepacked) by staff directly employed by the same business via shops, vans or office delivery rounds; or 4. Produced and delivered non- prepacked to a retail premise (e.g. from a central bakery to retail premises owned and run by the central bakery) and then sold non- prepacked from those premises. What about vending machines? Although there is no specific provision for vending machines under the FIC, it is recommended that those machines selling sandwiches should have a menu with the name of the food as well as the basics set out for reduced labelling, unless this information can be clearly read on the product pack from the outside of the machine. If the sandwiches are bought in from an outside supplier, they will be prepacked and must have the full nutritional declaration on the package itself THE FOOD INFORMATION REGULATIONS 2014 (FIR) REQUIREMENTS FOR NUTRITIONAL LABELLING ON FOODS KEY ACTION POINT 2: Decide if you wish to provide nutritional information on nonprepacked foods voluntarily If you need any further clarification on the types of foods that you offer, contact your local authority Environmental health department or Trading Standards office. Further details can also be found at https://www.food.gov.uk/ enforcement/regulation/fir/labelling

PRE-PACKED FOODS Section 4 NON PRE-PACKED FOODS Section 5 FOODS PRE-PACKED FOR DIRECT SALE Section 6 Are you making a health claim when describing this food? e.g. Rich in Vitamin D to help grow healthy bones and teeth YES NO No mandatory nutritional labelling required Do you want to label the nutrition information voluntarily? YES NO This product must be labelled with the Full Nutritional Declaration The Nurtitional Label must appear in one of these formats (you decide) No further action is required Full Nutritional Declaration Section 8.1 Energy Value Fat Saturates Carbohydrate Sugars Protein Salt Energy Value Only Section 8.2 NO Energy Value + 4 Section 8.3 Energy Value + Fat Saturates Sugars Salt Do you want to provide the vitamin and mineral content YES Vitamins & Minerals MUST be expressed as a % of reference intake. Section 8.1

7. WHAT ARE THE BENEFITS OF PROVIDING THIS INFORMATION VOLUNTARILY? If you decide not to provide this nutritional information on a voluntary basis, then you do not need to take any further action on nutritional labelling. Some TUCO members believe that they have a moral obligation to provide this information for their customers, to encourage healthy eating and in turn to help improve the health of their community. Some suggest that there is an increasing demand for this information, as more people become aware of healthier options and that customers are more knowledgeable and health conscious about what they consume following media reports on obesity epidemics and other health issues related to food and drink consumption. The TUCO Student Eating and Drinking Habits report, March 2014 recommends: A proportion of diet conscious students have indicated that they are conscious of eating a healthy diet most of the time. This is an important consideration for university catering as within this, health conscious students are mindful they do not consume excessive fat, sugar or calories; which will impact on their health and weight. It is recommended that students are offered low fat, low sugar alternatives which are affordable. If you think that it would be beneficial to your customers to receive nutritional information and would like to provide it for them, there are a number of points to consider: 1 What needs to be included on the label and how must the information be presented? 2 How will we make sure that the information that you provide is accurate? KEY ACTION POINT 3: If you want to give the nutritional information on nonprepacked foods voluntarily, decide how much information you want to give.

8. WHAT INFORMATION WILL YOU HAVE TO PROVIDE? If you wish to provide the information on non- prepacked foods voluntarily you must use one of the following formats: 1. The Full Mandatory Nutritional Declaration This would include all of the information that is mandatory for prepacked foods as shown in the label in section 4, including: Energy Value, Fat, Saturates, Carbohydrate, Sugars, Protein and Salt All must be expressed per 100g or 100ml and you can choose to add per portion and/or consumption unit. If you also wanted to add vitamin and mineral content, these would have to be expressed as a percentage of Reference Intake. Reference Intakes (RIs) are a means of communicating maximum recommended nutrient intake to the public. Reference Intakes replaced the term Guideline Daily Amount (GDA), although the principles behind both are the same. Some front of pack labels give the nutritional elements as a percentage of reference intake. 2. The Energy Value Only This can be measured per 100 g for solids or per 100ml for liquids and/ or per portion or per consumption unit. The energy value has to be expressed in both kilojoules (kj) and kilocalories (kcal). You can voluntarily express this as a percentage of reference intake but if you do this, you will need to also state what the reference intake is of an average adult (8400KJ/2000kcal) 3. The Energy Value plus Fat, Saturates, Sugars and Salt (Energy + 4) This can be measured per 100 g/ml and/or per portion or consumption unit. Again, you can voluntarily express this as a percentage of reference intake. There is no requirement to meet the minimum font size requirements that are applied to prepacked foods and the EUFIC does not specify where the information needs to be placed. KEY ACTION POINT 4: If you want to give nutritional information on non- prepacked foods voluntarily, ensure that the information is accurate.

9. HOW CAN WE ENSURE THAT THE INFORMATION IS ACCURATE? The accuracy of the nutritional information that you provide will depend upon having stringent and robust methods of analysing the nutritional content of the foods and ingredients that you buy, adhering to standardised recipes and having strict portion control. Some TUCO members are using specialist catering management software such as Saffron, Star Chef, Nutricalc and Caternet to help with this complex task. The software has many uses; recipe and menu management, stock control and purchasing, but they can also provide nutritional labelling too. Whilst we cannot recommend specific systems, we have spoken to some of our members who use the systems and here are some of the pro s and con s that they have illustrated. THE PRO S: The systems help you to present the complex nutritional information in a way that complies with the Food Information Regulations (FIR) and you can choose which method of information presentation you prefer. Some suppliers link directly with these systems to update the nutritional and allergen data on a regular basis. The system can help you to make simple adjustments to recipes in order to make them healthier. They give you the information in easily understandable formats, like the traffic light system and this can be passed on easily to your customers here is an example kindly supplied by University of South Wales THE CONS: The accuracy of the nutritional information depends upon the end user preparing the recipes exactly to specification, including the weighing out of each ingredient and service of the correct portion. Any deviation from this will result in the nutritional information being inaccurate. Therefore, it may not be suitable for self- service operations. Where suppliers are not connected directly to the system, it relies upon you to input the ingredient data and this can very time consuming. The system can easily become outdated if changes in ingredients are not reviewed and corrected on a regular basis. You have to remember that the system may not always take the method of cooking into account and this can affect nutritional values.

10. DESCRIBING DISHES, FOOD NAMES AND MENU DESCRIPTIONS There have been recent prosecutions, by the Trading Standards Authority, that concern caterers who have falsely described their dishes. All names and descriptions must give an accurate representation of the true nature of the food that is being served. This includes names and descriptions on menus, blackboards and adverts but also any illustrations. THE FOLLOWING ARE EXAMPLES OF COMMON MISLABELLING PROBLEMS THAT YOU MAY FIND USEFUL: Meat Products - Products described, as Ham must be sliced from a cured piece of meat from the hindquarters of a pig. Turkey substitute products are not made from ham and should not be described as this or as turkey ham on the menu. Similarly, reconstituted ham cannot be described as Ham. Traditional names such as roast pork or roast beef must not be used to describe joints that have been boiled then flash roasted. Roast joints should be cooked in the oven for the whole process. Claims must only be made about the percentage (%) of beef or ham that food contains (e.g. a burger) if it is true. Making a claim that food contains more than that declared is misleading and a false description. Bread and Butter must only be used if butter is being used and not if margarine or low fat spread is used. The term Homemade must only be used to describe food that has been made on the premises and has not been mass- produced elsewhere. The term Fresh must not be used to describe previously frozen or reconstituted products. The term Vegetarian must only be used when describing foods that do not contain any products derived from animals, i.e. gelatine and animal rennet

11. CAN WE MAKE SPECIFIC HEALTH CLAIMS? You may want to make and publish health claims about your dishes in order to encourage your customers to make healthy choices. The piece of legislation that covers this is Regulation (EC) 1924/2006 on nutrition and health claims made on foods. The legislation is very complex and mostly aimed at food manufacturers but does cover caterers too. Our advice would be that if you were going to make a health claim about a dish, you would need to ensure that this is backed up by accurate nutritional information. If you have made a specific health claim about a certain foodstuff, under the regulations you must provide the full nutritional declaration. Once again, if you are in any doubt you should contact your local authority trading standards office. If you advertise healthy choices, you must ensure that all of the elements of those choices are within healthy guidelines not just one of them. Healthy can mean different things to different people. So, for example, if you advertise a cottage pie as a healthy choice because it is low in fat you need to make sure that it is also low in sodium, saturates and sugar too. This would require you to know enough about the nutrition content of a dish to be sure that it met the conditions for making the claim. If you, as the caterer, don t know the amount of certain nutrients in your dishes, there are other ways in which you could tell consumers about the steps you ve taken to make products healthier: You are not allowed to claim any specific health benefits about your food, or claim that it can reduce symptoms or cure a medical condition. Instead talk about what steps you are taking to improve the foods you offer in a factual way, without referring to any associated health benefits. For example, we have added more vegetables to our pizzas would not be a claim whereas we are using less cheese on our pizzas to help you lose weight and keep your heart healthy includes a health claim. You may also find you can make claims about the ingredients you are using rather than the finished products, in which case you would only need to know

the nutritional content of the ingredient, which your supplier may be able to give you. For example, instead of saying all of our puddings are low in fat you could say we use skimmed milk when we make our delicious custard because it s low in saturated fat. You must make clear to customers exactly what it is that a particular claim is being made about, as implying that the overall product is low in saturated fat when it is not would be misleading. You may find it easier to make nutrition claims about dishes, such as low fat or low calorie, and this could have the advantage of making the claimed benefit clearer to customers than a general reference to a product being healthy. Nutrition claims such as low fat, high in fibre and low calorie can be used as long as they are included in the EU list of authorised nutrition claims and products using the claims comply with the set criteria as follows: Nutrient Claim Low Fat (solids) Low Fat (liquids) Low in Saturated Fat Low (total) sugars Sugar Free Low salt High in Fibre Low energy/calorie (solids) Low Energy/calorie (liquids) Legal limit No more than 3g of fat per 100g No more than 1.5g of fat per 100ml No more than 1.5g of saturated fat per 100g No more than 5g sugar per 100g Must contain less than 0.5g sugar per 100g No more than 0.3g salt per 100g Must contain more than 6g fibre per 100g No more than 40kcal per 100g No more than 20kcal per 100ml KEY ACTION POINT 5: Make sure you have accurate nutritional information to back up any claims that you make when you are describing your dishes.

12. HOW ELSE CAN WE ENCOURAGE HEALTHY EATING IN OUR OPERATION? Whether you decide that nutritional labelling is an option for your operation or not, there are other ways in which you can encourage healthy eating; RESEARCH WHAT YOUR CUSTOMERS WANT Carry out your own customer research or use other helpful resources, such as the TUCO studies to find out the trends and preferences around healthier choices. TRAIN YOUR STAFF Train your team members to understand the fundamental principles of nutrition and a healthy diet. So that they are able to: Plan healthy menus Give guidance on and encourage customers to eat healthily Interpret labels on pre-packed foods Apply healthy methods of ingredient choice, food preparation and cooking. DESIGN A HEALTHY FOODS POLICY Having a policy will demonstrate your commitment to providing healthy options. It could include details of your methods to promote healthy eating such as: Cutting down on less healthy cooking methods Purchasing healthier ingredients Increasing fruit and/or vegetable content in appropriate dishes Recipe/ menu changes to decrease energy density; fat and sugar reduced in products, or substituted with other lower calorie ingredients Reductions to portion sizes of existing products/ menu items Making fruit and vegetables more widely available across all food outlets Restricting the use of salt in recipes.

PROMOTE HEALTHY EATING Organise promotions and events based around healthy eating, this could include: Advice and guidance sessions Cookery lessons Use of loyalty cards or price reductions on healthier items Placing healthier options more prominently in the food display Smaller portion size options.

13. HOW ELSE CAN WE ENCOURAGE HEALTHY EATING IN OUR OPERATION? Every effort has been made to ensure that these guidance notes are as helpful as possible. However, it is ultimately the responsibility of the reader to ensure that their operation complies with the law. Businesses with specific queries may wish to seek the advice of their local authority. KEY ACTION POINT 1: Analyse your products and decide if you have to provide nutritional declarations for any of them in order to comply with the Food Information any of them in order to comply with the Food Information Regulations. KEY ACTION POINT 2: Decide if you wish to provide nutritional information on nonprepacked foods voluntarily Written and compiled by Fiona Horne of Bowthornes Ltd for TUCO Ltd

KEY ACTION POINT 3: If you want to give the nutritional information on non- prepacked foods voluntarily, decide how much information you want to give. KEY ACTION POINT 4: If you want to give nutritional information on non- prepacked foods voluntarily, ensure that the information is accurate. KEY ACTION POINT 5: Make sure you have accurate nutritional information to back up any claims that you make when you are describing your dishes.

The University Caterers Organisation, 20 Dale Street, Manchester M1 1EZ Tel: 0161 713 3420 Web: www.tuco.ac.uk Email: info@tuco.ac.uk Twitter: @TUCOltd